Comment submitted by Large Public Power Council (LPPC)

Summary: The Large Public Power Council (LPPC), an association of the nation's 29 largest non-federal public power systems, supports the EPA's move toward a risk-based, site-specific regulatory approach for coal combustion residuals (CCR). They argue that current "one-size-fits-all" national standards are overly conservative and unworkable, and they propose specific revisions to improve regulatory clarity, promote beneficial use, and align requirements with actual site-specific risks.